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Bombay High Court

Shelf Drilling Offshore Services India ... vs The Assistant Commissioner Division I ... on 29 August, 2023

Author: G. S. Kulkarni

Bench: G. S. Kulkarni

2023:BHC-OS:9070-DB
                                                                                     5.WPL8916_2023.DOC


   Vidya Amin

                         IN THE HIGH COURT OF JUDICATURE AT BOMBAY
                            ORDINARY ORIGINAL CIVIL JURISDICTION

                                  WRIT PETITION (L) NO. 8916 OF 2023

                 Shelf Drilling Offshore Services (India) Pvt. Ltd.          ... Petitioner
                                    Versus
                 The Assistant Commissioner, Division-I, CGST                ...Respondents
                 and Central Excise & Anr.
                 Mr. Jay Bhansali for the petitioner.
                 Mr. Vijay Kantharia a/w. Mr. Dhananjay B. Deshmukh for the
                 respondents.
                                        _______________________
                                    CORAM:           G. S. KULKARNI &
                                                     JITENDRA JAIN, JJ.
                                    DATED:           29 August, 2023
                                         _______________________
                 P.C.
                1.     This petition assails an order dated 16 January, 2023 passed by the

                Additional Commissioner, CGST and Central Excise Appeals-I whereby the

                petitioner's appeal against an order dated 17 January, 2022 passed by the

                Assistant Commissioner, CGST and Central Excise, Division-I, Mumbai South

                Commissionerate, which pertains to claim for interest under section 56 of the

                CGST Act, 2017 in case of refund applications in question, has been disposed

                of in the following terms by granting part interest:


                              "Thus, appellant is eligible for interest till date of payment is
                              credited in bank account. Hence, I find merit in their
                              submission that delay period taken after issuancec of RFD-05 as
                              indicated in table above till the money is credited in bank
                              account is eligible for interest. Accordingly, in all four refund
                              cases, I find that delay caused in crediting the bank account of
                              the appellant from the date of issue RFD-05, is eligible for
                              interest @6% p.a. under Section 56 of the Central GST Act.

                                                  Page 1 of 2
                                                29 August, 2023
                                                                                           5.WPL8916_2023.DOC




                                                           ORDER

The appeal filed by the appellant is allowed to the extent discussed above."

2. The contention of the petitioner is that the appeal should have been allowed granting the prayers as made for interest to be paid to the petitioner as per the provisions of Section 56 of CGST Act. In our view, the order passed by the Additional Commissioner is an appealable order under section 107 of CGST Act, 2017. There is no urgency for this Court to adjudicate on the impugned order in the proceedings of Writ Petition filed under Article 226 of the Constitution. We permit the petitioner to lodge an appeal before the Appellate Tribunal as and when so constituted. If such an appeal is filed within three months of the constitution of the Tribunal, the same be decided on its own merits and without an objection as to limitation. All contentions of the parties on merits are expressly kept open.

3. Disposed of in the above terms. No costs.

                     (JITENDRA JAIN, J.)                                       (G. S. KULKARNI , J.)




                                                         Page 2 of 2
Signed by: Vidya S. Amin                               29 August, 2023
Designation: PS To Honourable Judge
Date: 30/08/2023 11:01:16